Answer And Counterclaim To Complaint For Divorce With Children

Answer and Counterclaim to Complaint for Divorce (with Children) September 2017 Page 1 of 8 STATE OF WYOMING ) IN THE DISTRICT COURT ) ss COUNTY OF ) JUDICIAL DISTRICT Plaintiff:, ) Civil Action Case No. (Print name of person filing) ) ) vs. ) ) Defendant:. ) (Spouse) (Print name) ANSWER AND COUNTERCLAIM TO COMPLAINT FOR DIVORCE (WITH CHILDREN) The Defendant sets forth the following as the answers and responses to Plaintiff222s Complaint for Divorce (with Children): 1. Defendant admits the allegations in Paragraphs (list paragraphs that are accurate statements) of Plaintiff222s Complaint for Divorce. 2. Defendant denies the allegations in Paragraphs (list paragraphs that you believe are not accurate) of Plaintiff222s Complaint for Divorce. 3. Defendant does not have information sufficient to either admit or deny the allegations in Paragraphs . WHEREFORE, Defendant respectfully requests that the court find generally in his or her favor and against the Plaintiff, that Plaintiff take nothing by way of his or her Complaint for Divorce, and for such other and further relief as the court deems just and proper. COUNTERCLAIM DEFENDANT, sets forth the following as the counterclaim to Plaintiff222s Complaint for Divorce (with Children): 1. Plaintiff Defendant is a resident of County, Wyoming, where the Complaint was filed. The Plaintiff Defendant has lived in the State of Wyoming for at least sixty (60) days immediately prior to the filing of the Complaint; OR If not, the American LegalNet, Inc. www.FormsWorkFlow.com Answer and Counterclaim to Complaint for Divorce (with Children) September 2017 Page 2 of 8 marriage took place in Wyoming and the Plaintiff Defendant has lived in Wyoming from the time of the marriage until the filing of the Complaint.) W.S. 247 20-2-104 and 20-2-107(a). 2. Plaintiff and Defendant were married to each other on in (Date of Marriage) . (City, County and State where marriage took place) 3. The Plaintiff and Defendant separated on . (Date of Separation) 4. Irreconcilable differences exist in the marriage and Defendant is the aggrieved party in this case and should be granted a divorce from the Plaintiff. 5. The Plaintiff and I are the natural or adoptive parents of the following minor child(ren): Child222s initials: Child222s year of birth: Present address: Child222s residence for the past 5 years: Dates (From/To) Address (city and state) where child lived Name and current address of person(s) child lived with /present * / / / / / Attach a separate sheet if necessary Child222s initials: Child222s year of birth: Present address: American LegalNet, Inc. www.FormsWorkFlow.com Answer and Counterclaim to Complaint for Divorce (with Children) September 2017 Page 3 of 8 Child222s residence for the past 5 years: Dates (From/To) Address (city and state) where child lived Name and current address of person(s) child lived with /present * / / / / / Attach a separate sheet if necessary Child222s initials: Child222s year of birth: Present address: Child222s residence for the past 5 years: Dates (From/To) Address (city and state) where child lived Name and current address of person(s) child lived with /present * / / / / / Attach a separate sheet if necessary American LegalNet, Inc. www.FormsWorkFlow.com Answer and Counterclaim to Complaint for Divorce (with Children) September 2017 Page 4 of 8 Child222s initials: Child222s year of birth: Present address: Child222s residence for the past 5 years: Dates (From/To) Address (city and state) where child lived Name and current address of person(s) child lived with /present * / / / / / Attach a separate sheet if necessary 6. That the child(ren) named in the Complaint for Divorce have have not been in the State of Wyoming for a period of six (6) months or more immediately before filing of the Complaint. (If not, seek the advice of a lawyer before filing.) 7. I have not participated as a party or a witness or in any other capacity in any other court case concerning the custody of the minor child(ren), and no other court proceedings concerning the minor child(ren) (including proceedings for enforcement, domestic violence, protective orders, termination of parental rights or adoptions) are currently pending in the State of Wyoming or in any other state; OR I have participated as a party or witness or in another capacity in another court proceeding concerning the custody, allocation of decision-making, or visitation/parenting time of the child(ren) listed in the Complaint for Divorce as follows: (Please be specific and include the case number, court, state and nature of case, date of child-custody determination, if any, and the initials of the child(ren) involved) 8. I know of no person not a party to these proceedings who has physical custody of the minor child(ren) or who claims to have custody or visitation rights with respect to the minor child(ren); OR American LegalNet, Inc. www.FormsWorkFlow.com Answer and Counterclaim to Complaint for Divorce (with Children) September 2017 Page 5 of 8 The following people are not parties in this matter, but have physical custody of the child(ren) or claim rights of parental responsibilities, legal custody or physical custody, or visitation/parenting time with the child(ren): (List Names and Addresses) 9. To the best of Defendant222s knowledge, Neither party is pregnant, OR The Plaintiff Defendant is pregnant [If pregnant, consult an attorney. Your divorce may not be able to be final until after the baby is born.]; and The baby is due on or about (date), (and, check one space below): The Plaintiff and Defendant are the biological parents of the child, OR Plaintiff is not the biological parent of the child, OR Defendant is not the biological parent of the child. 10. Plaintiff OR Defendant is a fit and proper person to have the primary care, custody and control over the minor child(ren) subject to the other parent222s right of reasonable visitation; OR Both parties are fit and proper persons to share custody and control over the minor child(ren). 11. Plaintiff OR Defendant is capable of paying child support in an amount determined by the Wyoming Child Support Guidelines. 12. The Court should order that Plaintiff OR Defendant OR Both Parents provide medical insurance for the minor child(ren) if it can be obtained through an employer or if it is otherwise reasonably available and that Plaintiff OR Defendant OR Both Parents be liable to pay any medical expenses, including any deductible or co-pay, not covered by insurance coverage. 13. The parties have accumulated certain property and debts during the course of their marriage which should be equitably divided by the Court. 14. The Court should award the Plaintiff OR Defendant spousal support/alimony in a reasonable amount to be determined by the Court based on the Plaintiff's Defendant's need and the Plaintiff's Defendant's ability to pay as follows: Plaintiff's Defendant's need: (use additional paper if necessary) Plaintiff's Defendant's ability to pay: (use additional paper if necessary); American LegalNet, Inc. www.FormsWorkFlow.com Answer and Counterclaim to Complaint for Divorce (with Children) September 2017 Page 6 of 8 OR Neither party shall be awarded spousal support/alimony. 15. The Plaintiff222s Defendant222s previous name may be restored if he or she desires. WHEREFORE, the Defendant respectfully requests that the Court: 1. Grant the Defendant a divorce from the Plaintiff and dissolve the marriage; 2. Award: a. The parties joint legal custody and Plaintiff or Defendant to have physical custody; OR b. The parties joint legal and joint physical custody; OR c. Plaintiff or Defendant to have sole legal and physical custody; OR d. Other (Please describe desired legal and physical custody arrangement in detail) 3. Order that the Plaintiff OR Defendant pay child support in an amount determined by the court using the Wyoming Child Support Guidelines; 4. Order that the Plaintiff OR Defendant OR Both parents provide medical support for the minor child(ren); 5. Order a just and equitable division of the marital property and debts; 6. Order that: No party is entitled to spousal support; OR Reasonable spousal supp